Dangerous Substance and explosive Atmosphere Regulations 2002 DSEAR
From the outset please be aware that this post is not as an advertisement or attempt to obtain any form of Hazardous Area Classification or DSEAR Risk assessment works. It is also not intended to be trigger (and I apologise if it does) to any persons who feel that it is directed towards them for whatever reason. It is purely based upon observations from the last 15 years having looked over multiple independent DSEAR Assessments by various companies an consultants in the course of my work, as if I am called to complete an DSEAR assessment and an assessment already exists then I need to read it in order to ascertain and establish what has gone on before.
I find that we have to normally provide a lot more information if I am derating a hazardous zone to a lower severity or to perhaps non-hazardous, as opposed to increasing an existing hazardous zone or non-hazardous area to a hight level or severity. In all instances in our assessments either calculations are shown, computations software has been used or references to the standard providing the relevant standard model for such situations has been applied.
You would think after the 20 years that the DSEAR Regulations have been in place that a competence or governance framework would not have been drafted or introduced by now to regulate and control the various standard of consultants, contractors and organizations within this field of consultancy putting themselves forward as DSEAR Assessors.
ACOP L138 in its simplicity gives the impression that anyone can read that publication and complete a DSEAR Assessment competently. In reality although it is only in my personal opinion, it covers the Risk Assessment element well, but glosses over the Hazardous Area Classification element leading to over simplification of a complex subject matter.
Although both elements form part of the same subject matter, the skill sets required to competently carry out both the DSEAR Risk Assessment and Hazardous Area Classification elements differ greatly. The qualifications and relevant experience required to complete both well are varied.
The health and safety consultant or assessor is well suited to identifying hazards and formulating a report/assessment identifying potential risks although there knowledge of chemistry, and engineering concepts may be limited and they are best perhaps suited to simpler elementary assessments when conducting assessments on their own.
The process engineer/chemist is suited for complex applications where different substances are mixed together and obtaining different states depending upon the pressures exerted and temperatures applied. This can cause the mixed substances to combine and form potentially more complex structures or chemical substances and compounds that requires their skillset to identify those more complex hazards and risks.
The plant manager/process operator is suited to identify issues in the process/operation which can cause dangerous situations to occur and identify where the various substances are vented, pressure relieved and unloaded. How the substances are transported, handled, stored and utilized on a daily basis. They also know the maintenance operations required which might increase the risk of a potential fire and explosion.
This is why I have found over the years that the quality of DSEAR Assessment being completed are in the majority greatly flawed in their findings. Over classification is common place which leads normally too expensive Atmosphere Explosive (ATEX) Electrical and mechanical works to be required that actually wasn’t needed.
To try and put this into perspective/context an area which is over assessed where an electrical light and light switch might later be required to be installed will vary greatly in requirements and cost over the life of the installation.
An overclassified are where it should have been perhaps found non-hazardous a standard light and light switch (Non ATEX) would have sufficed. This might cost perhaps £100 to £250 for materials and £100 and £250 to install if the installation was simple. Whereas not that it has been over assessed it will require an ATEX Version which might cost between £400 to £800 for the materials and perhaps upwards of £450 to install.
Also the first standard installation if the area is non-hazardous only requires it to be electrically inspected perhaps ever 5 years over the next 25 years at let us say £250 per visit for. 5 visits equating to a total 25 year inspection life cycle cost of £1,250 for labour.
Whereas if the area is over assessed the ATEX Installation (if qualified skilled persons are not based upon site) will require a CompEx Electrician to install, inspect and maintain. The periodic inspection frequency may only be a maximum of every 3 years provided that sample inspections are conducted in between due to the lack of skilled persons employed upon site and depending on the risk of an ignition perhaps every 6 months.
This could equate to between 25 and 50 separate inspections over the life of the installation and you can assume it will be charged at a day rate if that is all that is to be inspected at a minimum of £280 and only going upwards in labour cost depending upon the contractor. This could in fact be a final life cycle maintenance cost over 25 years off between £7,000 and £14,000 labour cost.
That should help explain the cost risk associated in over assessment. Whereas the cost risk of under assessment and missing a hazardous area altogether could be greater in impact leading to loss of facility and life.
I am unsure if the reasons for over assessments are due to the lack of experience and competence by the persons conducting the average assessment, or if they are caused by a lack of confidence due to their experience and competence making them potentially risk adverse leading to their hedging their bets on over classification. Also to be considered is that they do not have to bear the initial and ongoing costs involved for their client in compliance once a hazardous zone has been established.
DSEAR Risk assessment and Hazardous Area Classification is not cheap. Yet nobody bulks at taking their car for repair at £75.00 per hour because its easier, and you normally go to them rather than they come to you. You might give it to your mate down the road to do it cheaper but what competence and insurance will he have for the work.
It might be that due to the costs of assessment some DSEAR Assessors feel obliged to actually find a hazardous zone to warrant the costs incurred. These charges are normally depending upon how they had to quote the works and if their client actually had a scheme of requirements for the works to be conducted.
As clients normally do not understand the requirements of DSEAR and what they actually want completed, to alleviate this as a company we quote what we call a DSEAR Stage 1 assessment which identifies all the hazardous substances being stored, their quantities and how they are being used, transported or processed upon site and any sources of release and type of release that may be occurring. This is based at a lower cost as the final documentation and overall assessment is less onerous and in the majority of cases should produce findings that either conclude that the process being conducted or substance being stored is considered as Non-Hazardous regarding DSEAR Explosion or DSEAR Increased Fire Risk, or that a further in depth DSEAR Stage 2 assessment is required.
An in depth DSEAR Stage 2 assessment includes the identification of the type of release and its extent, the assigning of Hazardous Areas/Zones and production of any Hazardous Area Classification drawings showing plan and elevation views to enable a 3D conceptualisation of the hazardous zone to be found. It also covers the ATEX Equipment Explosion Protection Levels (EPL) required for each area and may also contain if required a Consequence of Ignition Assessment, and Ignition Hazard Assessment along with any requirement for signage and training. The additional cost for the Stage 2 assessment can be mentioned in the initial costing/quotation as (If required) and the client then knows what they might have to uplift their final costs to at the outset of the works.
Most assessments and facilities shouldn’t find anything relevant to requiring a Stage 2 DSEAR Assessment and Hazardous Area Classification requirement.
A short list of typical areas that require Hazardous Area Classification are Paint Spray Booths, Wood working Extraction Equipment, Natural Gas installations and metering equipment, potentially compressed gasses upon site e.g. cylinders if the required separation distances have not been adhered to or the correct built storage facilities erected. Refuelling areas or fuel storage, Flammable processing equipment and so forth. This list can go on and on.
To all persons requiring a DSEAR assessment it is up to you to vet your subcontractor as to their suitability and competence. To be honest in most instances you are going to be on a hiding to nothing and in the hands of the gods as to what you end up with.
That being said there are some though few competent assessor working in the field but it will be up to you to cut the wheat from the chaff.
That is why I honestly believe there should be some sort of governance or decent formal qualification for DSEAR Risk Assessment and Hazardous Area Classification. The courses currently available are limited in their scope normally lasting 3 days to a week, and a comprehensive course would take a minimum of 4 weeks to deliver to cover the basic standards and their interpretation and implementation available.
This would cover as a minimum before letting an assessor loose plus conducting at least 2 assessments that are peer reviewed should be the following:
BSEN 60079-10-1 Hazardous Area Classification Explosive Gas Atmospheres
BSEN 60079-10-2 Hazardous Area Classification Explosive Dust Atmospheres
Energy Institute EI15 Safe Code of Practice for installations handling flammable substances
IGEM/SR/25 Hazardous Area Classification Natural Gas Installations
UKLPG Code of Practice No. 1
British Compressed Gasses Association (Various standards)
Along with the various BSEN Requirements for Safety for spray booths, wood working chip extractions systems, battery installations and so forth as a minimum.
Once again this article is solely my personnel opinion and not that of my companies. It is not intended to trigger anyone into a ranting or raving about their competence or abilities as you will notice I have not mentioned or covered my qualifications or experience to that point.
The post is intended to those perhaps contemplating competing a DSEAR Assessment in house themselves or looking to employ an assessor to inform them of considerations to take into account during the process. I though it also best placed on the public forum as opposed to the members forum for the widest audience.